Then, when this issue was addressed with KDHE and city staff ONSITE, obvious first-year mistakes were made by this professional staff. The excavated material must be segregated during excavation as per Kansas and EPA regulations. It is incredible that the onsite staff did not require what is common industrywide practice. Worker complaints about burning eyes are indicative of obviously very high odor response threshold screening levels which is in excess of 500 ppm according to the AIHA field services manual, RCRA Field Service manual, and NFPA guidance.

Any petroleum impacted soil under federal and state regulations cannot be located or “landfarmed” in an any area impacting waterways, watersheds, or groundwater recharge areas. The location of the material from a underground storage tank or remediation site showed an extreme disregard for regulations as well as exhibiting lack of sound professional judgment.

KDHE should get out of the consulting business and quit competing with the Kansas private sector environmental consultants and contractors and focus on the business of regulation. It is deplorable that KDHE, which should be a leader in environmental concerns, exhibits conduct of this level.

Dana E. Brown,

Lawrence